Compliance with SEEMP Part III involves more than laying down a concrete plan for cutting carbon emissions, as shipowners must also consider impacts on capital and operating expenditure.
What is SEEMP Part III?
From 1 January 2023, ships of 5,000 GT (Gross Tonnage) and above must have a verified Ship Energy Efficiency Management Plan, or SEEMP Part III, on board to document how their vessel plans to achieve its Carbon Intensity Indicator (CII) targets. The CII is a rating system for ships that the International Maritime Organization (IMO) developed. This will be a mandatory measure under MARPOL Annex VI, which comes into force in 2023.
The plan must include a description of how the vessel will operate and maintain its fuel efficiency throughout the year in line with its overall objective of reducing CO2 emissions and meeting its CO2 reduction commitments. SEEMP Part III documentation is in addition to SEEMP Part I and SEEMP Part II.
SEEMP includes:
- methodology for calculating the ship's attained annual operational CII and the processes that will be used to report this value to flag;
- the required annual operational CII, for the next three years;
- an implementation plan on how the required annual operational CII will be achieved during the next three years; and
- a procedure for self-evaluation and improvement.
Which vessels must have SEEMP Part III on board?
The SEEMP Part III applies to any vessel on international voyages of 5,000GT and above, and is one of the following ship types defined in MARPOL Annex VI, Regulation 2: bulk carrier, combination carrier, containership, cruise passenger ship, gas carrier, general cargo ship, LNG carrier, refrigerated cargo carrier, ro-ro cargo ship, ro-ro cargo ship (vehicle carrier), ro-ro passenger ship, tanker.
Our recommended next steps for SEEMP Part III and CII
Planning
Start now by understanding and planning your SEEMP Part III:
- Calculate your CII rating to find out where you are now, and the year-on-year impact assuming no changes are made
- Articulate your three-year target – what is required to maintain a minimum rating, and how you can achieve a rating higher than C
- Prepare a three-year implementation plan including, for example, the energy efficiency measures you require to maintain pace with tightening CII targets
Implementation
Once you have your SEEMP Part III on board, you need to start executing your articulated plan, including the implementation of some or all of your energy efficiency measures, if required.
Monitoring
SEEMP Part III is a dynamic document and each year it needs to be updated with prevailing fuel consumption data, allowing you to tangibly start tracking your CII performance and the effectiveness of your energy efficiency measures
Self-evaluation and improvement
Each year, evaluate whether you accomplished what you set out to achieve and if not, why.
How LR can help
We can assist ship owners and operators with the following:
- SEEMP Part III template: to ensure you comply with regulatory requirements, we have designed a SEEMP Part III template with comprehensive guidance on how to complete it.
- SEEMP Part III advisory: our advisory experts are available to assist you in preparing your SEEMP Part III plan, as well as vessel-specific analysis for improving your CII rating if required.
- SEEMP Part III verification: submit your SEEMP Part III to us for review as soon as possible to ensure its onboard the ship by 1 January 2023.
Our SEEMP Part III advisory services include:
- The preparation of ship specific SEEMP Part III, particularly when it comes to energy efficiency measures
- A 3-year implementation plan to achieve your company’s targeted CII for each ship
- A review of SEEMP Part I if required
- A vessel-specific analysis for improving operation CII if required
Our trusted advisory experts are available to prepare a SEEMP Part III for each of your vessels, including the required Carbon Intensity Indicator (CII) rating for the next three years, and a 3-year implementation plan to achieve your company’s targeted CII rating for the vessel.
Once we understand the percentage reductions that you require to maintain compliance with the CII requirements and targets, then we can map out what energy efficiency measures you can implement as an owner-operator to comply, and more importantly, phase in over the next few years to remain in compliance. We will also advise on the impact these changes have on your company in terms of OPEX and CAPEX.
SEEMP Part III template
To ensure you comply with regulatory requirements, we have designed a SEEMP Part III template with comprehensive guidance on how to complete it.
Calculate your CII rating
Use our calculator to review your vessel’s Carbon Intensity Indicator rating (A to E).
